2. Prevention of Pollution by Harmful Substances
Carried by Sea in Packaged Form
Regulations for the Prevention of Pollution by Harmful Substances Carried by
Sea in Packaged Form are contained in Annex III of MARPOL 73/78.
The Marine Environment Protection Committee (MEPC) at its 55th session in
October 2006 adopted the revised MARPOL Annex III Regulations for the
prevention of pollution by harmful substances carried by sea in packaged form.
The Annex has been revised to harmonize the regulations with the criteria for
defining marine pollutants which have been adopted by the UN Transport of
Dangerous Goods (TDG) Sub-Committee, based on the United Nations Globally
Harmonized System of Classification and Labelling of Chemicals (GHS).

3. The regulations were developed in order to identify marine pollutants so that they
could be packed and stowed on board ship in such a way as to minimise accidental
pollution as well as to aid recovery by using clear marks to distinguish them from
other (less harmful) cargoes.
The rules on discharging harmful goods are straightforward: "Jettisoning of harmful
substances carried in packaged form shall be prohibited, except where necessary
for the purpose of securing the safety of the ship or saving life at sea".
The Annex states that "appropriate measures based on the physical, chemical and
biological properties of harmful substances shall be taken to regulate the washing of
leakages overboard, provided that compliance with such measures would not impair
the safety of the ship and persons on board." (MARPOL Annex III, Regulation 7 (1))
The Annex applies to all ships carrying harmful substances in packaged form, or in
freight containers, portable tanks or road and rail tank wagons.
The regulations require the issuing of detailed standards on packaging, marking,
labelling, documentation, stowage, quantity limitations, exceptions and notifications,
for preventing or minimizing pollution by harmful substances.

4. However, implementation of the Annex was initially hampered by the lack of a clear
definition of harmful substances carried in packaged form. This was remedied by
amendments to the International Maritime Dangerous Goods Code (IMDG Code) to
include marine pollutants.
The IMDG Code was first adopted by IMO in 1965 and lists hundreds of specific
dangerous goods together with detailed advice on storage, packaging and
transportation. The amendments extending the Code to cover marine pollutants,
which entered into force in 1991, added the identifier "marine pollutant" to all
substances classed as such. All packages containing marine pollutants must be
marked with a standard marine pollutant mark.
Annex III of MARPOL was also amended at the same time, to make it clear that
"harmful substances are those substances which are identified as marine pollutants
in the International Maritime Dangerous Goods Code (IMDG Code)." (Regulation 1).
Annex III is optional so that States who sign up to MARPOL 73/78 Annexes I and II
are not required to adopt the Annex at the same time. Annex III received sufficient
ratifications by 1991 and entered into force on 1 July 1992.

5. A new chapter for MARPOL Annex VI – requirements for technical and operational
measures to improve the energy efficiency of international shipping
By Edmund Hughes, Technical Officer, Marine Environment Division, IMO
February 2013
New regulations aimed at improving the energy efficiency of international
shipping entered into force on 1 January 2013.
The amendments to the International Convention for the Prevention of Pollution
from Ships (MARPOL) were adopted in July 2011.They add a new chapter 4
Regulations on energy efficiency for ships to MARPOL Annex VI, to make
mandatory the Energy Efficiency Design Index (EEDI), for new ships, and the
Ship Energy Efficiency Management Plan (SEEMP) for all ships. Other
amendments to Annex VI add new definitions and the requirements for survey
and certification, including the format for the International Energy Efficiency
Certificate.
The regulations apply to all ships of 400 gross tonnage and above. However,
under regulation 19, the Administration may waive the requirements for new
ships up to a maximum of 4 years.

6. The EEDI is a non-prescriptive, performance-based mechanism that leaves
the choice of technologies to use in a specific ship design to the industry. As
long as the required energy-efficiency level is attained (regulations 20 and 21),
ship designers and builders would be free to use the most cost-efficient
solutions for the ship to comply with the regulations.
The SEEMP establishes a mechanism for operators to improve the energy
efficiency of ships. Regulation 22 requires ships to keep on board a ship
specific Ship Energy Efficiency Management Plan (SEEMP).

7. Enhancing energy efficiency
Shipping is permanently engaged in efforts to optimize fuel consumption. And,
while ships are universally recognized as the most fuel-efficient mode of bulk
cargo transportation, the Second IMO GHG Study, published in 2009,
identified a significant potential for further improvements in energy efficiency,
mainly through the use of already existing technologies such as more efficient
engines and propulsion systems, improved hull designs and larger ships: or, in
other words, through technical- and design-based measures that can achieve
noteworthy reductions in fuel consumption and resulting CO2 emissions on a
capacity basis
(tonne-mile). The study also concluded that additional reductions could be
obtained through operational measures such as lower speed, voyage
optimization, etc.
The EEDI addresses the former type of measure by requiring a minimum
energy efficiency level for new ships; by stimulating continued technical
development of all the components influencing the fuel efficiency of a ship; and
by separating the technical and design-based measures from the operational
and commercial ones.
The SEEMP provides a management framework, that may form part of the
ship’s safety management system, for improving the energy efficiency of a ship
whilst operating at sea and in port,.

8. Applicability
The EEDI formula – as presently drafted – is not supposed to be applicable to all new
ships of 400 gross tonnes and above engaged in international trade. Indeed, it is
explicitly recognized that it is not suitable for all ship types (particularly those not
designed to transport cargo) or for all types of propulsion systems (e.g., ships with
diesel-electric, turbine or hybrid propulsion systems will need additional correction
factors).
Indeed, the first iteration of the EEDI has been purposefully developed for the largest
and most energy-intensive segments of the world merchant fleet, thus embracing
approximately 70 per cent of emissions from new ships and covering the following
ship types: tankers, gas carriers, bulk carriers, general cargo ships, refrigerated cargo
carriers and container ships.
For ship types not covered by the current formula, suitable formulae will be
developed in due course to address the largest emitters first. IMO’s Marine
Environment Protection Committee (MEPC) is poised to consider the matter in detail
at future sessions, with a view to adopting further iterations of the EEDI.

9. All existing ships of 400 gross tonnes and above engaged in international trade are
required to implement and maintain a SEEMP which establishes a mechanism for
operators to improve the energy efficiency of ships. This should be achieved by
monitoring the energy efficiency performance of a ship’s transportation work and at
regular intervals considering new technologies and practices to improve energy
efficiency.
The SEEMP will offer operators of existing ships the chance to reduce costs
immediately by saving fuel. As the regulation does not set any energy efficiency
requirements it will be up to the industry to proactively utilize SEEMP to ensure they
optimize the fuel saving benefits. In the end it is in the industry’s best interests to
utilize the SEEMP as with fuel accounting for
over 50% of operational costs, keeping fuel costs in check is a major factor in the
industry’s economic health. Such an approach will be important to achieving both
sustainable development and economic goals for the industry going forward.

10. A set of such guidelines was adopted by MEPC 63 (March 2012) intended to
assist in the implementation of the mandatory regulations on Energy Efficiency for
Ships in MARPOL Annex VI:
resolution MEPC.212(93) – 2012 Guidelines on the method of calculation of the
attained Energy Efficiency Design Index (EEDI) for new ships;
resolution MEPC.213(93) – 2012 Guidelines for the development of a Ship
Energy Efficiency Management Plan (SEEMP);
resolution MEPC.214(93) – 2012 Guidelines on survey and certification of the
Energy Efficiency Design Index (EEDI); and
resolution MEPC.215(93) – Guidelines for calculation of reference lines for use
with the Energy Efficiency Design Index (EEDI).

11. Minimum propulsion power
The need for a minimum propulsion power to be incorporated into the EEDI formula
has been duly acknowledged and, to that end, regulation 21.5 of MARPOL Annex VI
states that “For each ship to which this regulation applies, the installed propulsion
power shall not be less than the propulsion power needed to maintain the
manoeuvrability of the ship under adverse conditions as defined in the guidelines to
be developed by the Organization.”
It should, therefore, be clear that IMO fully supports the view that a minimum
installed power to maintain safe navigation in adverse (weather) conditions is of
critical importance to ensure both the safety and efficiency of international shipping.
While the EEDI instrument therefore contains the standard to be achieved on this
matter, implementation of that standard will be enabled through guidelines that are
also to be adopted. IMO circular MSC-MEPC.2/Circ.11 provides “Interim Guidelines
for determining minimum propulsion power to maintain the manoeuvrability of ships
in adverse conditions”.

12. Fuel efficiency and engine power
Although the easiest way to improve a vessel’s fuel efficiency is, indeed, to
reduce speed – hence the move to slow steaming by a significant number of
ships – there is a practical minimum at which fuel efficiency will decrease as a
vessel is slowed down further.
There are other technical ways to improve fuel efficiency, such as waste heat
generators, which do not impact on speed (they impact on auxiliary engines).
Indeed, improvements in road transport efficiency have been made through
advances in technology that have, however, not led to a sacrifice in speed;
rather, quite the opposite.

13. It has been (wrongly) argued that the EEDI limits installed power and so induces
owners to use small-bore high-rpm engines, thereby increasing fuel consumption.
However, a reduction of installed power does not require a reduction in engine bore
and increasing rpm. The easiest way to reduce power would be to “de-rate” the
exact same engine by limiting the “maximum” rpm (remember, horsepower = torque
multiplied by rpm).
This would have the impact of increasing propeller efficiency (if the exact same
propeller is installed), as propeller efficiency will generally improve as rpm
decreases. Another practical way to reduce installed horsepower is to install an
engine with one cylinder fewer.
This would have no impact on specific fuel consumption or rpm. Such engines can
be identified by reference to the catalogues of major engine manufacturers.
Of course, there are “economies of scale” in ships’ fuel efficiency.
The larger the ship (at a given speed), the lower the fuel consumption per unit of
cargo. However, such economies of scale are limited by trade considerations,
physical port limitations (generally, draft) or cargo logistics issues. Therefore, ships
tend to be designed to be as large as practical for a given trade.

14. Effectiveness of EEDI and SEEMP in
reducing emissions from ships
The EEDI, in establishing a minimum energy efficiency requirement for new ships
depending on ship type and size, provides a robust mechanism that may be used
to increase the energy efficiency of ships, stepwise, to keep pace with technical
developments for many decades to come. It is a non-prescriptive mechanism that
leaves the choice of which technologies to use in a ship design to the
stakeholders, as long as the required energy-efficiency level is attained, enabling
the most cost-efficient solutions to be used. Such technologies have been
comprehensively considered in the 2009 IMO GHG Study and are now frequently
highlighted by the shipping media.
A consequence of the new regulations, and the growing interest and demand for
innovative energy efficiency improving technologies, is leading to significant
investment in research and development. Fuel oil consumption represents a
significant element of the cost of operating a ship today.

15. The effective implementation of SEEMP onboard a ship could lead to a
reduction in fuel used, and so could be considered a commercial imperative, as
much as a regulatory one, for those seeking to manage a ship in today’s market.
To enable the ship’s energy efficiency performance is be optimised the
operational energy efficiency measures employed either at sea or in port need
to be robustly monitored and appropriate benchmarking tools used. Comparing
the energy efficiency performance of one ship with that of a similar ship on the
same trading route is also possible but this is more complicated as energy
efficiency of different ships can be affected by many variables, not least, the
weather and sea conditions they each experience.
A proactive approach to energy management of a ship should deliver
cost improvements for the business and a reduction of emissions from ships for
wider society.